Revenue Scotland and Tax Powers Act 2014 section 87

Amendment of self-assessment during enquiry to prevent loss of tax

Section 87 allows Revenue Scotland to amend a taxpayer's self-assessment during an ongoing enquiry where the officer believes the tax stated is too low and delay would risk a loss of tax.

• A designated officer may amend a self-assessment during an enquiry if the tax stated is insufficient and delay would likely cause a loss of tax to the Crown.
• Where the enquiry is limited to matters arising from a taxpayer's own amendment to the return, the officer's power to amend only extends to any deficiency caused by that amendment.
• Once the officer issues a notice of amendment under this section, the taxpayer loses the normal right to amend their own return.
• Any additional tax arising from the amendment must be paid immediately upon receiving the notice, and the enquiry period runs from the date the notice of enquiry was given until the date the enquiry is completed.

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